CIR v. First Express Pawnshop Digest
CIR v. FIRST EXPRESS PAWNSHOP G.R. Nos. 172054-46, 16 June 2009 Facts: In this case, respondent a pawnshop company received the tax assessment on 3 January 2002. On 1 February 2002, respondent submitted its protest and attached the GIS and Balance Sheet as of 31 December 1998. Since petitioner did not act on the protest during the 180-day period,respondent filed a petition before the CTA on 28 August 2002 and contended that petitioner did not consider the supporting documents on the interest expenses and donations which resulted in the deficiency income tax. Within 60 days from the filing of protest or until 2 April 2002, respondent should submit relevant supporting documents. Respondent, having submitted the supporting documents together with its protest , did not present additional documents anymore. In a letter dated 12 March 2002, petitioner requested respondent to present pro...